Preview
FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
-------------------------- X
YVETTE McCLAMB,
Index No. 154374/2018
Plaintiff,
VERIFIED REPLY TO
- against - CROSS-CLAIMS OF
DEFENDANTS KALAHARI
HOUSING PARTNERSHIP DEVELOPMENT CONDOMINIUM, BOARD OF
CORPORATION, KALAHARI CONDOMINIUM, MANAGERS OF KALAHARI
THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, and
CONDOMINIUM, WALLACK MANAGEMENT CO., WALLACK MANAGEMENT CO.
INC., RNC INDUSTRIES, LLC and WEST NEW
YORK RESTORATION OF CT, INC.,
Defendants.
---------------------------------------------- X
Defendant, HOUSING PARTNERSHIP DEVELOPMENT CORPORATION,1y itsattorneys,
DEVITT SPELLMAN BARRETT, LLP, as and for its Verified Reply to the Cross-Claims of
defendants, KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF KALAHARI
CONDOMINIUM and WALLACK MANAGEMENT CO., upon information and belief, states as
follows:
ANSWERING THE FIRST CROSS-CLAIM OF DEFENDANTS
KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF
KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO.
FIRST: Denies each and every allegation contained in paragraphs numbered and
"13," "14" "15"
designated as and of the Cross-Claim.
ANSWERING THE SECOND CROSS-CLAIM OF DEFENDANTS
KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF
KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO.
SECOND: Denies each and every allegation contained in paragraphs numbered and
1 of 4
FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018
"16" "17"
designated as and of the Cross-Claim.
ANSWERING THE THIRD CROSS-CLAIM OF DEFENDANTS
KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF
KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO.
THIRD: Denies each and every allegation contained in paragraph numbered and
"18"
designated as of the Cross-Claim.
WHEREFORE, defendant, HOUSING PARTNERSHIP DEVELOPMENT CORPORATION,
demands judgment dismissing the cross-claims herein, together with the costs and disbursuniosits ofthis
action.
Dated: Smithtown, New York
August 14, 2018.
Yours, etc.,
DEVITT SPELLMAN BARRETT, LLP
Attorneys for Defendant, HOUSING
PARTNERSHIP DEVELOPMENT CORP.
50 Route 111, Suite 314
Smithtown, New York 11787
(631) 724-8833
Our File No. HC8645W9C [KEW/ch]
By:
KELLY E. RIG
TO: LAW OFFICE OF MARGARET G. KLEIN & ASSOCIATES
Attorneys for Defendants, KALAHARI CONDOMINIUM,
BOARD OF MANAGERS OF KALAHARI
CONDOMINIUM and WALLACK MANAGEMENT CO.
2nd
200 Madison Avenue, Floor
New York, New York 10016
(646) 392-9250
2
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FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018
RHEINGOLD GIUFFRA RUFFO & PLOTKIN, LLP
Attorneys for Plaintiff
29th
551 Fifth Avenue, FlOOr
New York, New York 10176
(212) 684-1880
PERRY, VAN ETTEN, ROZANSKI & PRIMAVERA, LLP
Attorneys for Defendant, RNC INDUSTRIES, LLC
60 Broad Street, Suite 3600A
New York, New York 10004
(212) 406-9710
STRADLEY RONON STEVENS & YOUNG, LLP
Attorneys for Defendant, WEST NEW
YORK RESTORATION OF CT, INC.
100 Park Avenue, Suite 2000
New York, New York 10017
(212) 812-4132
3
3 of 4
FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018
NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018
VERIFICATION
STATE OF NEW YORK )
ss.:
COUNTY OF SUFFOLK )
The undersigned, an attorney admitted to practice in the Courts of the State ofNew York, states,
that affirmant is a member of the firm of DEVITT SPELLMAN BARRETT, LLP, the attorneys for
defendant HOUSING PARTNERSHIP DEVELOPMENT CORPORATION, that affirmant has read the
Defendants'
foregoing Reply to Cross-Claims and knows the contents thereof, and thatthe same istrue
to the affirmant's knowledge, except as to the matters therein stated to be alleged upon information and
belief, and that as to those matters affirmant believes to be true.
That the reason this Verification is made by affirmant and not by the defendant is because the
defendant's residence is located outside the County wherein affirmant's office is located and that the
source of affirmant's knowledge and the grounds of belief as to those matters therein stated to be
alleged on information and belief are correspondence and investigations which have been made
concerning the subject matter in this action, and which are in the possession of the said attorneys.
The undersigned affirms that the forcgaing statcmeñts are true, under the penalties of perjury.
Dated: Smithtown, New York
August 14, 2018
K LYE. GHT
4
4 of 4
Preview
FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------- X YVETTE McCLAMB, Index No. 154374/2018 Plaintiff, VERIFIED REPLY TO - against - CROSS-CLAIMS OF DEFENDANTS KALAHARI HOUSING PARTNERSHIP DEVELOPMENT CONDOMINIUM, BOARD OF CORPORATION, KALAHARI CONDOMINIUM, MANAGERS OF KALAHARI THE BOARD OF MANAGERS OF KALAHARI CONDOMINIUM, and CONDOMINIUM, WALLACK MANAGEMENT CO., WALLACK MANAGEMENT CO. INC., RNC INDUSTRIES, LLC and WEST NEW YORK RESTORATION OF CT, INC., Defendants. ---------------------------------------------- X Defendant, HOUSING PARTNERSHIP DEVELOPMENT CORPORATION,1y itsattorneys, DEVITT SPELLMAN BARRETT, LLP, as and for its Verified Reply to the Cross-Claims of defendants, KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO., upon information and belief, states as follows: ANSWERING THE FIRST CROSS-CLAIM OF DEFENDANTS KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO. FIRST: Denies each and every allegation contained in paragraphs numbered and "13," "14" "15" designated as and of the Cross-Claim. ANSWERING THE SECOND CROSS-CLAIM OF DEFENDANTS KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO. SECOND: Denies each and every allegation contained in paragraphs numbered and 1 of 4 FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018 "16" "17" designated as and of the Cross-Claim. ANSWERING THE THIRD CROSS-CLAIM OF DEFENDANTS KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO. THIRD: Denies each and every allegation contained in paragraph numbered and "18" designated as of the Cross-Claim. WHEREFORE, defendant, HOUSING PARTNERSHIP DEVELOPMENT CORPORATION, demands judgment dismissing the cross-claims herein, together with the costs and disbursuniosits ofthis action. Dated: Smithtown, New York August 14, 2018. Yours, etc., DEVITT SPELLMAN BARRETT, LLP Attorneys for Defendant, HOUSING PARTNERSHIP DEVELOPMENT CORP. 50 Route 111, Suite 314 Smithtown, New York 11787 (631) 724-8833 Our File No. HC8645W9C [KEW/ch] By: KELLY E. RIG TO: LAW OFFICE OF MARGARET G. KLEIN & ASSOCIATES Attorneys for Defendants, KALAHARI CONDOMINIUM, BOARD OF MANAGERS OF KALAHARI CONDOMINIUM and WALLACK MANAGEMENT CO. 2nd 200 Madison Avenue, Floor New York, New York 10016 (646) 392-9250 2 2 of 4 FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018 RHEINGOLD GIUFFRA RUFFO & PLOTKIN, LLP Attorneys for Plaintiff 29th 551 Fifth Avenue, FlOOr New York, New York 10176 (212) 684-1880 PERRY, VAN ETTEN, ROZANSKI & PRIMAVERA, LLP Attorneys for Defendant, RNC INDUSTRIES, LLC 60 Broad Street, Suite 3600A New York, New York 10004 (212) 406-9710 STRADLEY RONON STEVENS & YOUNG, LLP Attorneys for Defendant, WEST NEW YORK RESTORATION OF CT, INC. 100 Park Avenue, Suite 2000 New York, New York 10017 (212) 812-4132 3 3 of 4 FILED: NEW YORK COUNTY CLERK 08/17/2018 02:43 PM INDEX NO. 154374/2018 NYSCEF DOC. NO. 21 RECEIVED NYSCEF: 08/17/2018 VERIFICATION STATE OF NEW YORK ) ss.: COUNTY OF SUFFOLK ) The undersigned, an attorney admitted to practice in the Courts of the State ofNew York, states, that affirmant is a member of the firm of DEVITT SPELLMAN BARRETT, LLP, the attorneys for defendant HOUSING PARTNERSHIP DEVELOPMENT CORPORATION, that affirmant has read the Defendants' foregoing Reply to Cross-Claims and knows the contents thereof, and thatthe same istrue to the affirmant's knowledge, except as to the matters therein stated to be alleged upon information and belief, and that as to those matters affirmant believes to be true. That the reason this Verification is made by affirmant and not by the defendant is because the defendant's residence is located outside the County wherein affirmant's office is located and that the source of affirmant's knowledge and the grounds of belief as to those matters therein stated to be alleged on information and belief are correspondence and investigations which have been made concerning the subject matter in this action, and which are in the possession of the said attorneys. The undersigned affirms that the forcgaing statcmeñts are true, under the penalties of perjury. Dated: Smithtown, New York August 14, 2018 K LYE. GHT 4 4 of 4